Texas CSF Compliance

Overview

The Texas Cybersecurity Framework provides a structured approach to cybersecurity for state agencies built upon the NIST Cybersecurity Framework. It organises security controls around the core functions of Identify, Protect, Detect, Respond, and Recover, supplemented by Texas-specific requirements for governance and reporting.

DIR requires agencies to designate an Information Security Officer and establish a cybersecurity program that addresses risk management, access control, incident response, and business continuity. The framework recognises that agencies vary in size and complexity, and allows for risk-based control selection.

The biennial information security assessment is a central mechanism for tracking statewide cybersecurity posture. Assessment results inform DIR's understanding of systemic risks and guide the allocation of statewide cybersecurity resources and shared services.

TX-CSF integrates with other compliance requirements commonly applicable to Texas agencies, including CJIS Security Policy, HIPAA, IRS Publication 1075, and FERPA. The NIST-based structure facilitates mapping across these standards, helping agencies manage multiple compliance obligations efficiently.

Key Areas

• Identify - asset management, business environment, governance, risk assessment, and risk management strategy
• Protect - access control, awareness and training, data security, information protection, maintenance, and protective technology
• Detect - anomalies and events, security continuous monitoring, and detection processes
• Respond - response planning, communications, analysis, mitigation, and improvements
• Recover - recovery planning, improvements, and communications for restoring services
• Governance - cybersecurity governance structures, policies, and executive oversight specific to Texas requirements
• Supply Chain Risk Management - managing cybersecurity risks in the supply chain and third-party relationships
• Privacy - protecting personally identifiable information in accordance with Texas privacy laws

Who It's For

• Texas state agencies responsible for managing government information resources
• Institutions of higher education in Texas subject to DIR cybersecurity requirements
• Information security officers designated under Texas Government Code
• IT and security teams within Texas government entities implementing cybersecurity controls

Core Requirements

Policies and Governance

Agencies must designate an Information Security Officer, establish cybersecurity policies approved by agency leadership, and implement a governance structure that oversees the security program. Annual reporting to DIR on security posture and incidents is mandatory.

Risk Management

Agencies must conduct regular risk assessments to identify threats to information resources, evaluate the likelihood and impact of those threats, and implement risk mitigation strategies. Risk assessments must inform the selection and prioritisation of security controls.

Security Controls

Controls aligned with NIST CSF functions must be implemented across all security domains. This includes access controls, encryption, network security, endpoint protection, vulnerability management, and configuration management tailored to the agency's risk profile.

Incident Response

Agencies must establish and maintain incident response plans, report cybersecurity incidents to DIR within required timeframes, and participate in state-level incident coordination. Plans must include procedures for containment, eradication, recovery, and post-incident review.

Evidence and Reporting

Agencies must complete biennial security assessments and submit results to DIR. Ongoing evidence of control implementation, risk management activities, and incident response preparedness must be maintained to support audits by the State Auditor's Office.

Implementation Steps

1. Scope and objectives - Identify all information resources within the agency's responsibility, including systems, data, and personnel. Establish cybersecurity objectives aligned with DIR requirements, applicable state and federal regulations, and the agency's mission.
2. Gap assessment - Conduct an assessment against TX-CSF control requirements to identify gaps in current cybersecurity practices. Evaluate maturity across each framework domain and prioritise improvements based on risk to agency operations and citizen data.
3. Control implementation - Implement controls across all framework domains, addressing access management, data protection, network security, monitoring, and incident response. Deploy solutions appropriate to the agency's size, complexity, and risk profile.
4. Evidence and documentation - Document all policies, procedures, and control implementations. Prepare for the biennial security assessment by collecting evidence of control operation, risk management activities, and incident response readiness.
5. Review and continuous improvement - Review security posture regularly and update controls based on new threats, audit findings, and changes in state or federal requirements. Participate in DIR-coordinated exercises and leverage shared services offered by the state.

Frequently Asked Questions

Who must comply with the Texas Cybersecurity Framework?

All Texas state agencies and institutions of higher education are required to comply. Compliance is mandated under Texas Government Code Chapter 2054 and overseen by the Texas Department of Information Resources (DIR), with results reported to the Texas Cyber Command.

How many control objectives does TX-CSF have?

TX-CSF covers 42 control objectives across five NIST CSF functions - Identify, Protect, Detect, Respond, and Recover - plus Texas-specific requirements for governance and supply chain risk management. Agencies must assess their maturity against all 42 objectives in the biennial DIR assessment.

How is compliance assessed?

Agencies complete a biennial information security assessment covering all 42 control objectives and submit results to DIR. Results are reviewed by the Texas Cyber Command, which uses the data to identify systemic vulnerabilities and direct statewide cybersecurity resources.

How does TX-CSF relate to TAC §202 and NIST 800-53?

TX-CSF is built on NIST SP 800-53 Rev 5, which is separately mandated for all Texas state agencies under TAC §202. In practice, agencies need to satisfy both: TAC §202 requires implementing NIST 800-53 controls, while TX-CSF requires assessing maturity across 42 objectives that map to those same controls. MyCISO handles both in a single unified program.

What role does DIR play?

DIR oversees statewide cybersecurity, provides shared services and guidance, collects and analyses biennial assessment data, coordinates incident response, and reports cybersecurity posture to state leadership. DIR also sets statewide cybersecurity standards.

Does TX-CSF address federal compliance requirements?

TX-CSF's alignment with NIST standards helps agencies meet federal requirements. However, agencies handling specific federal data types (CJIS, HIPAA, IRS) must also comply with those specific federal standards.

What happens if an agency is non-compliant?

DIR tracks compliance through biennial assessments and works with agencies to develop improvement plans. Non-compliance may result in increased oversight, mandatory remediation plans, and reporting to state leadership.

Why It Matters

• TX-CSF compliance is mandatory - not optional. Every Texas state agency and institution of higher education must assess all 42 control objectives and report results to DIR biennially. Non-compliance triggers mandatory remediation plans, increased oversight, and reporting to the Governor's office and state legislature.
• The Texas Cyber Command uses biennial assessment data to identify systemic vulnerabilities across the state's technology infrastructure and direct cybersecurity resources. Agencies with weak postures are flagged for priority intervention. Strong TX-CSF performance protects your agency from that scrutiny and demonstrates security leadership to state leadership.
• TX-CSF is built on NIST SP 800-53, which is separately mandated under TAC §202 for all Texas state agencies. Rather than treating these as two separate compliance exercises, MyCISO maps TX-CSF control objectives directly to NIST 800-53 controls - so your team implements once and satisfies both requirements simultaneously.

Common Challenges

• Limited cybersecurity budgets and staffing within smaller state agencies and institutions
• Managing diverse technology environments with varying levels of legacy infrastructure across agencies
• Coordinating cybersecurity efforts across agencies with different missions, data types, and risk profiles
• Meeting multiple overlapping compliance requirements (state, federal, industry-specific) simultaneously
• Maintaining cybersecurity awareness and training for a large and distributed state workforce
• Keeping pace with evolving threats while managing day-to-day operational security responsibilities